Revenue Cycle Insider

More remote capabilities may mean more responsibilities — and oversight.

In September 2024, the Office of Inspector General (OIG) identified potential fraud in remote patient monitoring (RPM) and urged tougher oversight. The Centers for Medicare & Medicaid Services (CMS) agreed, and the most recent Medicare Physician Fee Schedule (MPFS) featured beginning steps to better manage RPM.

Find out what to expect when managing RPM.

Understand RPM Parameters

RPM consists of three parts. They are:

1. Enrollee education and device setup: How to use the device and transmit the health data; this helps ensure appropriate use of the device and accurate data collection.
2. Device supply: The device and the collection and transmission of at least 16 readings every 30 days; this ensures that the appropriate health information is supplied to the provider.
3. Treatment management: Provider review of the health data and use of it to manage the patient’s condition.

Payment for each of these components is separate, and the amount paid is not variable based on the type of device or the information collected.

Consider Investigation Results

The OIG investigation found that the use of RPM grew dramatically in the audit period reviewed (2019-2022).

Among the review’s key findings:

• RPM increased for both traditional Medicare and Medicare Advantage.

Note: The OIG reported that although this growth occurred during the COVID-19 pandemic, it does not appear to be entirely attributed to it. RPM steadily increased each year — in contrast to other telehealth services which rose drastically at the beginning of the pandemic inspring 2020, and then began to decline.

• The majority of RPM (94 percent) was for chronic conditions.
• About 43 percent of enrollees who received RPM did not receive all necessary components — raising questions about if these services are being used as intended.
• A total of 12 percent did not receive treatment management (i.e., never had a claim or encounter record for treatment management from any provider.) Patients who do not receive treatment management — at least 20 minutes of management services for a patient’s treatment plan, including at least one conversation between the provider and the patient — raises the question as to whether there was a real need for RPM to manage the patient’s health.
• Medicare lacks key information for oversight, including who ordered the monitoring for the patient.

The study concluded that there was a clear need to know how RPM is being used, including who is receiving it and for what conditions, as well as identification of weaknesses that may limit the oversight of these services.

CMS agreed and replied that OIG findings would be considered when determining appropriate next steps. They further advised many of the recommendations will require notice and comment rulemaking.

Review the full OIG Report and CMS response here.

What Exactly is RPM?

Background: The U.S. Department of Health and Human Services (HHS) Best Practice Guide defines RPM as a form of asynchronous telehealth — meaning patients and providers use medical devices to collect and electronically send patient data and clinical information without a live interaction between them.

Know this: The information is often collected outside of a healthcare setting.

Benefits: The provider reviews the patient’s health data and uses the information to manage their condition(s), detect and prevent health problems and adverse events, and facilitate patient communication and education.

Beyond the convenience, RPM helps patients stay engaged, become more knowledgeable about their health — often increasing their participation in their health — and encourages behavior change.

These Services Are Considered RPM

RPM is both remote physiological monitoring and remote therapeutic monitoring (RTM).

Remote physiologic monitoring involves the use of non-face-to-face technology to monitor and analyze a patient's physiological metrics (i.e., measurable biological functions). Examples include oxygen saturation, blood pressure, blood sugar or blood oxygen levels, and weight loss/gain.

RTM captures non-physiologic data related to a therapeutic treatment using a connected medical device. Examples include musculoskeletal or respiratory system data, treatment adherence (i.e., medication compliance) and treatment response (i.e., pain management).

Note: Only RTM data is permitted to be “self-reported” by the patient using the device.

Know These RPM Requirements

RPM requires:

• An established patient-physician relationship for remote physiologic monitoring; RTM does not.
• Monitoring that is medically necessary and reasonable.
• Patient consent only at the time RPM is furnished.
• Remote physiologic monitoring services to monitor an acute or chronic condition.
• Billing only for one of these services, not both. Remote physiologic monitoring and RTM cannot be billed together.
• Physiologic data be electronically collected and automatically uploaded to a secure location where the data can be available for analysis and interpretation by the billing practitioner.
• The device used to collect and transmit the data meets the FDA definition of a medical device, e.g., digital scale, heart, glucometer, bp or o2 monitors, and spirometers. 
• Only one practitioner bill per patient in a 30-day period.

Know this: Other healthcare personnel may provide the services under the general supervision of a billing practitioner.

See What Else Is New

There were no major changes to RPM rules and regulations in the 2025 MPFS, but providers received these clarifications and new directive alerts:

• Mandated the ability to use audio-only communication if the patient isn’t capable of, or doesn’t consent to, using video technology
• Reinforced requirement that data be collected for at least 16 days out of 30 days to ensure consistent monitoring throughout the billing cycle
• Added permission for concurrent billing of RPM and advanced primary care management (APCM) services when all applicable requirements for both are met
• Updated/added billing codes and payment rates
• Expanded coverage and broadened scope of reimbursable RPM for rural health clinics (RHCs) and federally qualified health centers (FQHCs)

Important: Change gives access to individual billing codes to improve payment accuracy and provide clarity to payers about which services beneficiaries receive.

Note: See the current list of separately billable base and add-on codes in MPFS Table 28.

Know this: There is a six-month transition period to update billing systems and procedures. Capable RHCs/FQHCs can begin billing individual HCPCS/CPT^® codes immediately to receive separate payment for these services.

What to Do Now?

To ensure your RPM reporting is in the right, you should:

1. Evaluate policies and procedures to ensure they align with all RPM requirements.
2. Review patient accounts to ensure they meet all the requisite elements (e.g., patient consent [as appropriate], a medical device that meets the Food and Drug Administration (FDA) definition, physiologic data is collected in the timeframe specified, all three components were provided and billed.)
3. Monitor CMS for updates including related notice and comment rulemaking.

Read more about RPM in the HHS Best Practice Guide linked above, and see the 2025 MPFS final rule for all the RPM details here.

Patricia Zubritzky, BS, CRCE-I, Contributing Writer, Pittsburgh